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Italian Visa Application center

Data Privacy Policy

Effective date: 25th of May 2018.

Your privacy is important to us. This policy serves to explain how we process your personal data when you apply for a visa through Capago.

1

Your Rights

Since we store your data in data centres located within the European Union, you have the right under the "General Data Protection Regulation", to request rectification, erasure, portability and access to your personal data from us.

Any personal data collected by Capago is controlled by Capago S.A., which is located at 9 Rue Raoul Dautry, 91190 Gif-sur-Yvette, France. Should you wish to implement any of your rights, you can reach Capago's Data Protection Officer using the email privacy@capago.eu

You can also object to the processing and transferring of your personal data. In such a case, this would imply that you do not wish to apply for a visa anymore. You can therefore cancel your visa application, which will automatically result in the processing and transferring of any of your personal data coming to an immediate halt.

2

Classification and Retention of Personal Data by Capago

In order to provide our services to travellers, Capago collects and processes personal data. Such data is classified into two categories:

  • Identifiers: Identifiers include any unique piece of data which is part of someone's identity. This includes name, surname, title, email, phone numbers, and passport numbers.
  • General Data: General data includes any data which is not an identifier. Examples of such data are your web-browser type, your appointment duration, the date and duration of your visit on our website, your satisfaction, your visa type, and your nationality.

Identifiers will be used by Capago only in order to offer and provide our services to you during your visa application process. This data is only kept from the day it is provided to us (i.e. when you book an appointment) up to a maximum of 30 days after you have collected your passport from us. Should you not arrive for your appointment, your identifiers will then be erased within 30 days after the appointment date.

One exception exists for legal purposes; the storage of invoices in PDF format, within a restricted and secure space in our software, is unlimited.

General data is used by Capago in order to monitor the quality of our services, as well as to provide better and improved information to the travellers we help. General data is kept for an unlimited amount of time, and automatically becomes fully anonymous data when the identifiers are erased.

3

Types of Personal Data Processed by Capago

Personal data processed using cookies and similar technologies

When you visit our websites we collect information such as the geographic location of your device, your browser language, your IP address, your browser type, the date and time of your visit, the number and the pages that you view, and the page elements (e.g. links) that you click.

When interacting with our contact centre agents using our live chat or Facebook messenger feature, we collect information such as your name and email address, time of contact, and chat history.

We may use technologies such as pixels, clear gifs, cookies or other similar tools on our websites or in messages sent to you during your visa application process. Some of the third parties that we use are Google analytics, Facebook and Live agent.

If you do not want us to collect such information, there is a simple procedure in most web-browsers which allows you to automatically prevent all of these technologies from communicating data to us. Some add-on or built-in web browser features can also ask you (on a case by case basis) if you wish to share data or not.

Personal data processed when contacting our contact centre

When contacting our contact centre - via mail, chat or phone - we store the full content of the conversation (audio recordings, mail threads, chat histories) associated with your unique identifier (email, chat ID, phone number).

This data is used for quality purposes, as well as fraud detection/prevention. This data is available to privileged administrators for an undefined period of time.

Personal data processed when you book an appointment

Personal data is collected when you book an appointment to apply for a visa in one of our branches. For each group of travellers, the first person in the group becomes the main contact. We ask this main contact to provide us with identifiers such as an email address, phone number and full name. This information is used whenever we need to contact you during the process. It is also stored after the appointment in PDF format on the invoice.

For each traveller in the group, exact information about the purpose of the trip, as well as full names, dates of birth and passport numbers, is collected. This information is required for us to determine which type of visa you are applying for and the amounts which should be collected on behalf of the consulates.

Names, dates of birth and passport numbers are identifiers, and are therefore kept only for the duration of the process at Capago. They are completely erased from our system no later than 30 days after the date you received your passport back from us.

The purpose of the trip is kept in order to allow us to provide reported data to the consulates about our activity.

Data processed when you come for your appointment

Data is collected when you come for your appointment. This data includes the waiting time and the processing time at each step. This data is kept for an unlimited period once it has been anonymised after the 30-day identifier retention period.

Biometric identifiers, such as your picture and fingerprints, are collected on behalf of the consulates we operate for. These identifiers are collected directly within the system provided to us by the governments we work for.

We might also digitise and capture part or all of the documentation that you provide us in the systems provided to us by the governments we represent.

We operate as a data processor on behalf of the governments we represent for both the biometric data and the visa application documentation. These governments therefore remain the data controllers.

4

Transfers and Recipients of Personal Data

Governments

The essence of Capago's contract with governments is to operate as a data processor on their behalf. Therefore, all documentation and biometric identifiers collected during your appointment at Capago are transferred to the consulates.

Other service providers

In order to provide our services, we use third-party software and tracking technologies such as Facebook pixel and Google analytics. We use the collected data to analyse how you interact with our platforms (websites, contact centres). While using these technologies, some of your personal data will be collected and hosted on these third-party platforms.

The use of the personal data collected through our website by these third parties is not only subject to our responsibility and settings. It is also conditioned by the privacy policy you will have accepted when/if you use these same platforms.

Therefore, we strongly encourage you to review your own personal settings on Facebook: https://www.facebook.com/ads/preferences

Should you not wish to be tracked via Google Analytics, you can use Google's plugin to prevent being tracked: https://tools.google.com/dlpage/gaoptout

5

Personal Data Collected from Third Parties

Our booking system allows for one person to book for other applicants. In such a case we might collect the Personal data of any person who has not yet accepted and agreed to our data privacy policy.

In this case, the individual "Validation Checklist" document, which summarises all information for each visa application, is used to inform each individual of their rights. This document must be signed by the owner of the data or their legal representative for minors.

6

Privacy Policy Updates

Capago reserves the right to update this privacy policy from time to time as we improve our services and as technologies and laws change.